As we noted in a previous post, on January 1, 2012, the California Transparency in Supply Chains Act of 2010 (the "Act") will become effective. This legislation will require every large retailer and manufacturer doing business in California to publicly disclose whether it has taken specified actions to eliminate slavery and human trafficking from its product supply chain. The Act does not require a company to make any effort to eliminate slavery or human trafficking, but only to disclose the extent, if any, to which it has taken the actions listed in the Act. The impact of the Act ultimately will depend on the extent to which consumers, investors and activists use the required disclosure to pressure companies to monitor and eliminate abuses in their supply chains. On August 1, 2011, federal legislation modeled on the Act was introduced.
This article provides further guidance on how to respond to the Act and was originally published in the State Bar of California’s Business Law News. To read the full article please click here.